View source for NUREG-1031, Forwards Safety Evaluation Re Emergency Operating Procedures Upgrade Program Per TMI Action Item 1.C.1.Eight Procedures Validated on Simulator & Actions Acceptable

{{Adams
| number = ML20236Q879
| issue date = 11/16/1987
| title = Forwards Safety Evaluation Re Emergency Operating Procedures Upgrade Program Per TMI Action Item 1.C.1.Eight Procedures Validated on Simulator & Actions Acceptable
| author name = Ferguson R
| author affiliation = NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
| addressee name = Mroczka E
| addressee affiliation = NORTHEAST NUCLEAR ENERGY CO.
| docket = 05000423
| license number = 
| contact person = 
| case reference number = RTR-NUREG-1031, TASK-1.C.1, TASK-TM
| document report number = GL-82-33, IEIN-86-064, IEIN-86-64, TAC-65842, NUDOCS 8711200339
| document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE
| page count = 3
| project = TAC:65842
| stage = Approval
}}

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Docket No. 50-423                                                                    i Mr. Edward J. Mroczka                                                              i Senior Vice President Nuclear Engineering and Operations Northeast Nuclear Energy Company Post Office Box 270' Hartford, CT 06141-0270

==Dear Mr. Mroczka:==

==SUBJECT:==
MILLSTONE NUCLEAR POWER STATION, UNIT 3 - EMERGENCY OPERATING PROCEDURES (EOP) UPGRADE' PROGRAM (TAC NO. 65842)
Section 13.5.2.3 of Supplement No. 4 to NUREG-1031, Safety Evaluation Report related to the operation of Millstone Nuclear Power Station, Unit No. 3 dated November 1985, indicated that there were five open issues related.to your program for preparing and implementing upgraded E0Ps; three issues were related to the Millstone Unit 3 Emergency Response Guidelines (ERGS) and were evaluated by the staff in SSER No. 5, dated January 1986. -The two issues remaining to be evaluated were:                                                    ,
(1) The applicant should submit a description of the process for determining needed instrumentation and control characteristics in accordance with the schedule for submitting the DCRDR program plan.
(2) The PGP should be revised to include a description of the reference method for validating the E0Ps (not required prior to full. power operation).
The staff's review has found that you have described a process that is acceptable  l for determining needed instrumentation and' control characteristics. The            j results of the staff's review of issue (1) are contained in SSER No. 4, Section 18.1, Control Room, dated November 1985.
1 The staff conducted an additional review of the description of the reference         '
method for validating submitted October 1, 1984, and also reviewed the description of.this validation method contained in the INP0 document,       .        i
                " Emergency Operating Procedures Validation Guidelines", which was referenced in the PGP. As a result of this review, the staff concludes that the description of the reference method for validating E0Ps, together with citing the INP0 document, is acceptable.                                                    ,
                                                                                                  -l 8711200339 871116                                                            !
DR   ADOCK 050004231                                                        !
PDR w-_-_-______

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2 In a letter from E. J. Mroczka to the NRC, dated June 26, 1987, you identified, during a self-initiated review of the PGP in response to Information Notice No. 86-64, " Deficiencies in Upgrade Programs for Plant Emergency Operating Procedures", August 14, 1986, that you had not completely met a commitment to validate all E0Ps using their plant-reference simulator and to train operators on all the E0Ps using the simulator during cold licensing training. You also stated that, although nine E0Ps were not initially validated on the simulator, they were validated using a walk-through technique to ensure that they were consistent and technically accurate and that all operators were trained on them. Further, as of April 1, 1987, eight of the nine E0Ps had been validated on the simulator; the exception, " Response to Inadequate Core Cooling", could not be modeled by the simulator. The staff finds these actions acceptable.
Enclosed is the staff's safety evaluation which documents the results of our review.         This report closes out TNI Action Plan Item 1.C.1 for Millstone 3 and our review of the deficiency in the E0P upgrade program identified in the {{letter dated|date=June 25, 1987|text=June 25, 1987 letter}}.
Sincerely, WIM1 $1TS $7fs Robert L. Ferguson, Project Manager Project Directorate I-4 Division of Reactor Projects I/II Office of Nuclear Reactor Regulation

==Enclosure:==

As stated cc w/ enclosure:
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NRC & Local PORs PDI-4 Files SVarga BBoger SNorris RFerguson OGC-Bethesda EJordan JPartlow JBongerra ACRS(10)                        7 P WL-SNorris PDI 4 RFerguson:bd PDh 11/ld/87                   11/jo/87 JSt J' x 11/$/87

Mr.. E. J. Mroczka                      Millstone Nuclear Power Station
           . Northeast Nuclear Energy Company        Unit No. 3 cc:                    ,
              . Gerald Garfield,' Esq.                  Ms. Jane Spector Day, Berry & Howard                     Federal Energy Regulatory Commission City Place                               825 N. Capitol Street, NE.
Hartford . Connecticut 06103-3499        Room 8608C .
Washington, D.C. 20426 Mr. Maurice R. Scully, Executive Director                              Mr. 'Kevin McCarthy, Director Connecticut Municipal Electric           Radiation Control Unit Energy Cooperative                    Department of Environmental Protection 268 Thomas Road                          State Office Building Groton, Connecticut 06340                Hartford, Connecticut 06115 Robert W. Bishop, Esq.                   Burlington Electric Department l              Corporate Secretary                      c/o Robert E. Fletcher, Esq.
l              Northeast Utilities                      271 South Union Street Post Office Box 270
* Burlington, Vermont- 05402 Hartford, Connecticut 06141 Mr. William J. Raymond Senior Resident Inspector Office U. S. Nuclear Regulatory Commission Millstone III P. O. Box 811 Niantic, Connecticut 06357-08 l              Mr. Michael L. Jones, Manager l              Project Management Department i              .Pbssachusetts Municipal Wholesale Electric Company Post Office Box 426 Ludlow, Massachusetts 01056 Regional Administrator
             - U. S. NRC, Region I 631 Park Avenue King of Prussia, Pennsylvania   19406 l
l              Mr. Karl Abraham Public Affairs Office, Region I U. S. Nuclear Regulatory Commission, King of Prussia, Pennsylvania 19406 d
i

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      ,[              g               NUCLEAR REGULATORY COMMISSION 7,,            j                        WASHINGTON, D. C 20655 kk.....,/
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION NORTHEAST NUCLEAR ENERGY COMPANY ET AL.
MILLSTONE NUCLEAR POWER STATION, UNIT NO. 3 DOCKET NO. 50-423 INTRODUCTION The staff's safety evaluation of November 1985 determined that the Procedures.
Generation Package (PGP), which was submitted in partial fulfillment of TMI Task Action Plan Item 1.C.1, was acceptable with the exception of five items; three items were related to their Emergency Operating Procedures (E0Ps), one-was related to the task analysis requirement of Generic. Letter 82-33, and one item was related to the validation description contained in the PGP. The items were:
(1) The staff requires that guidelines and criteria for the use of the RCS loop isolation valves during accident recovery be established before-operation above 5 percent of full power.
(2) The staff requires that the degraded core cooling guideline E0P 35 FR-C.2, be revised before operation above 5 percent of full power to direct the operator to the correct procedural E0P steps and to include l                 the use of RVLMS.
(3) The staff requires the applicant to revise the Millstone '3 E0Ps to include RVLMS set points corresponding to a 50 percent steam / water mixture with reactor coolant pumps running, or demonstrate that the proposed alternatives are acceptable before operation above 5 percent ~of full power.
(4) The applicant should submit a description of the process for determining needed instrumentation and control characteristics in accordance with the schedule for submitting the DCRDR program plan.
l          (5) The PGP should be revised to include a description of the " reference method" for validating the E0Ps (not required prior to full power operation).
Regarding items (1)-(3), the staff concluded in supplement number 5 to the safety evaluation report for the operation of Millstone Nuclear Power Station Unit No. 3, dated January 1986, that these items had been satisfactorily                              i addressed by the licensee in a letter from J. F. Opeka (NNECO) to V.S. Noonan (NRC),datedJanuary 14, 1986. The staff's review of items (4) and (5) is contained in the evaluation which follows.
                                                                                         . . .    &~ L.__ .a__ _

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In a ietter from E. J. l'roczka to the NRC dated, June P5,1987, which                      ;
c;ocumented the results of a PGP review initiated by the licensee in response to an NRC Information Notice, 86-64, " Deficiencies in Upgrade Programs for Plant Emergency Operatinc Procedures", dated August 14, 1986, the licensee indicated that they hac' not net a commitment made in the PGP to validate all E0Ps and train all licensed operators on all E0Ps using the simulator during cold license training, and provided an explanation for not meeting this commitment.                                                                                )
EVALUATION The staff's review of item (4) indicates that the licensee has described a process that is acceptable for determining needed instrurnentation and control             ,
characteristics. The results of the staff's review of this issue are                       4 contained in SSER No. 4 Section ,18.', Control Roon, dated November 1985.
I The staff reviewed the licensee's description of the " reference rethod" for validating E0Ps provided in their Procedures Generation Package (PGP) submitted October 1, 1984      The staff also reviewed the description of this validation method contained in the INPC docurent, " Emergency Operating                    ,
Precedures Validation Guidelines" (INPO 83-006), which the licensee indicated              i in their PCP was the basis for their validation program. The INPO document describes the " reference method" in detail. As a result of these reviews, the staff concludes that the licensee's abbreviated description in the PCP of the
                " reference method" for validating E0Ps and their citation of the INP0                     ;
document, which contains a detailed explanation of this method, adequately                   i addresses issue (5).                                                                        I 1
The staff has also reviewed the licensee's letter of June 23, 1987, in which               I they indicated that they had failed to meet a commitnent made in their PGP te validate all E0Ps and train all licensed operators on all E0Ps, using the simulator, during cold license training.      In the letter, the licensee stated that the cause of not meeting this commitment was poor connunication; the                    l personnel responsible for validating the E0Ps understood that validatire all E0Ps using the simulator was a corporate goal rather than a cormlitment made to the NRC. The licensee indicated; however, that all E0Ps had been valic'ated,                 I using a walk-through technique, in the fii11 stone Unit 3 control room during cold license training and that all operators were trained on all the ECPs                     I during cold license training in accordance with the training program described                l in the MP. The licensee further stated that eight of the nine E0Ps that did                   l not receive validation on the simulator as of April 1, 1987; one E0P, " Response             I to Inadequate Core Cooling", could not be validated on the simulator because the simulater cannct riodel the entry condition for this E0P. The licensee-initiated corrective actions described in the letter, which were verified by the staff in a telephone conversation with the licensee on October 19, 19P7, is satisfactory evidence that the licensee has now ret their PGP consnitment.

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t CONCLUSION                                                                         .
                                                                                           .z Based on this evaluation, the staff concludes the TMI Task-Action Plan. Item 1.C.1 is' closed ~and that the licensee has satisfactorily addressed.the commitment made.in their PGP to' validate E0Ps and train licensed. operators'on them using the Millstone Unit 3 simulator.
Dated: Wyyg                                                                     -1 Principal Contributor:  John Bongerra l
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